Whistleblowing system

Whistleblowing system

Internal and External Whistleblowing Hotline

ZOZO Group has established various channels, including external whistleblowing desks at law firms, for reporting compliance-related violations (*). These external desks are available 24/7, 365 days a year, and also accept reports in local languages from our group employees worldwide. We strictly adhere to the privacy of consultants and whistleblowers, allowing for anonymous reporting and ensuring no disadvantageous treatment is received due to whistleblowing.

Upon receiving a report, we promptly investigate the facts. If a violation is identified, we take corrective actions and implement preventive measures. To raise awareness among employees, we also provide ongoing training programs. The status of whistleblowing operations is regularly reported to the Board of Directors.

Facts subject to reporting
The facts subject to reporting include any and all acts of legal violation or suspected legal violation, as well as other inappropriate behaviors. This encompasses activities that violate employment regulations, other internal rules, actions against our basic policy on human rights, questionable accounting practices, and actions that may harm the social credibility of the company, and corruption among others.

No. of reported cases of whistleblowing

Whistleblowing Hotline for Business Partners

External Whistleblowing Hotline
An external whistleblowing hotline is available to employees of ZOZO Group’s business partners, including those who have left the company within the past year. Reports can be submitted anonymously. An external law firm receives reports and, depending on the nature of the case, conducts investigations to take appropriate action in collaboration with our internal reporting team.
External Whistleblowing Hotline

LY Corporation Group Whistleblowing Hotline
Business partners of LY Corporation Group companies (including anyone who has resigned in the past year) can make anonymous reports via this hotline. The whistleblowers can choose to make reports to either an external law firm or LY Corporation's Compliance Division. Depending on the nature of the case, the PIC of whistleblowing at Group companies will investigate and take appropriate actions.
LY Corporation Group Whistleblowing Hotline

Compliance

Compliance Committee

The Compliance Committee is established and convened for the purpose of formulating ethical behavior standards, preparing and implementing legal compliance manuals and compliance programs, as well as conducting operations such as checks. Additionally, In the event of a significant violation, we report it to the Board of Directors.

Compliance Training

To strengthen company-wide compliance awareness, ZOZO Group provides comprehensive compliance training for all employees, including part-time and temporary staff. These training sessions cover a wide range of topics, such as legal and regulatory compliance, anti-corruption, and the elimination of harassment, incorporating real-life case studies to deepen understanding and promote adherence to ethical standards. Additionally, for directors, and managerial positions including officers and division heads, we conduct group discussions based on case studies and specialized harassment prevention training. These sessions focus on preventive measures and appropriate responses to harassment, aiming to foster a workplace environment free from misconduct.

ZOZO Group Code of Conduct

1. Introduction
ZOZO Group Code of Conduct is a code to be observed by all executives and employees of ZOZO Group.

2. Commitment to compliance and ethical conduct
We abide by all laws and regulations, and practice ethical conduct that lives up to the trust provided by society.

3. Respect for basic human rights
･We respect the rights of individuals and do not tolerate discrimination or disadvantageous treatment on the basis of political beliefs, ideology, religion, gender, gender identity, sexual orientation, physical characteristics, disease, age, nationality, race, ethnicity, etc.
･We understand and respect the culture and customs of the countries and regions in which we operate, and act accordingly.
･We prohibit all forms of forced labor and child labor in accordance with laws and regulations.

4. Ensuring a safe, healthy and harassment-free work environment
･We do not tolerate sexual harassment, abuse of authority, or any other form of workplace harassment.
･We comply with laws and regulations concerning occupational safety and health, give consideration to the physical and mental health of our employees, and strive to ensure a safe and healthy work environment.

5. Responsibility to customers
･We comply with the applicable laws and regulations related to handling personal information in each market, and collect personal information from our customers in an appropriate manner in accordance with our Privacy Policy.
･We use the personal information we obtain within the scope of the purposes specified in our Privacy Policy, and appropriately protect, manage, and dispose of such information. In principle, we do not provide such information to any third party, except when we have obtained the consent of the customer or when permitted by applicable laws.
･We maintain fairness and honesty toward our customers and do not make misleading representations or engage in misleading conduct, so that our customers can use our services safely and comfortably.

6. Fair business practices
･We comply with the business competition laws of each country where we operate, conducting our business activities with a spirit of fair play and on the principles of free and fair competition, and do not impose unfair trading conditions on our business partners or service users.
･We do not obtain, or allow others to bring in, information about our competitors in an unfair manner.
･We comply with laws and regulations regarding imports and exports and other international trading rules.
･We do not engage in prohibited transactions with specified countries, regions, organizations, or individuals that are subject to economic sanctions.

7. Avoidance of conflict of interest
We act with respect for the interests of the company and do not use our position or status in the company to benefit ourselves or a third party.

8. Appropriate use and management of company assets
･We recognize that intellectual property rights are an important asset for the business of the ZOZO Group and appropriately protect those rights, while also respecting the intellectual property rights of third parties.
･We use, manage, and dispose of company assets and trade secrets appropriately, and do not use them for any purposes other than business.

9. Thorough implementation of information security
We strictly protect and manage our information assets, including customer information and l classified information, and do our utmost to protect them from unauthorized access, leakage, falsification, destruction, etc.

10. Accurate, fair, timely, and appropriate information disclosure
･We create accurate and complete accounting records.
･We disclose accurate information to society and the stock market in a fair, timely, and appropriate manner.
･We strictly manage insider information and do not engage in insider trading.

11. Maintenance of appropriate relationships with political entities and administration
We maintain appropriate relationships with political entities and administration, and do not give preferential treatment to any individual or organization that engages in political activities.

12. Prohibition on bribery and corruption
･We do not engage in any form of bribery, corruption, or corrupt practices, whether with public servants or private citizens.
･In order to ensure free and fair trade, we provide and accept business entertainment and gifts only to the extent deemed appropriate.

13. Rejection of relationships with crime
We reject any involvement with anti-social forces, organized crime syndicates, and other organized criminals, as well as criminal activities such as money laundering and terrorist financing.

14. Giving back to society and protecting the environment
We actively contribute to society and protect the environment through our business activities, taking into consideration the social and environmental impact of our business activities. We encourage our officers and employees to take an interest in these activities, and to actively participate in and support them.

15. Consultation and whistleblowing on compliance issues, and prohibition of retaliation
･If we discover any improper acts or suspected compliance violations, we consult or report them to our superiors, the Compliance Consultation Desk, or the Internal Reporting Desk.
･We prohibit any retaliation or disadvantageous treatment towards whistleblowers regarding compliance.

16. Revisions and eliminations
Revisions and eliminations of this policy will be made by our Board of Directors.

*ZOZO Group Code of Conduct is approved by the Board of Directors on April 21, 2023